Case File
efta-01415304DOJ Data Set 10OtherEFTA01415304
Date
Unknown
Source
DOJ Data Set 10
Reference
efta-01415304
Pages
14
Persons
0
Integrity
Extracted Text (OCR)
EFTA DisclosureText extracted via OCR from the original document. May contain errors from the scanning process.
Subject: RE: Assistance Required in solving rejection points on KYC
Casa
[I]
From: Vijay-A Sawant
Date: Wed, 01 Aug 2018 04:40:36 -0400
To: Bradley Gillin
Cc: Stewart Oldfiel
Good Morning Brad/Stewart,
I have received following 'new' rejection points on this case, as follows,
see me comments in red below —
Reason for Rejection:7/31
A — Please provide a recent document that will serve as address proof. The
IRS document is from September, 2016. — Could you provide latest (July 18)
bank statement for this entity? This should resolve this request.
B — Nature of Business: What do they do with the artwork? Do they purchase
it and re-sell it? Does the trust only hold artwork as assets? — As per
constitutional docs, the purpose of Prytanee LLC is for engaging in the
acquisition, ownership & management of artwork for investment purposes. I
had already updated this but it seems they want more info on re-selling
part. Could you advise on this please?
C — Please check to see if there is a memo that was accompanied by Chip
Packard's approval. If there is none, I recommend "refreshing" the approval
with current senior management. The current e-mail approval does not address
what exactly is being discussed and approved. — Kindly provide this please.
D — The address of employer for Caroline is missing. In addition, please
include how long she has been with that company etc. — For Caroline, I have
now updated Sotheby's Switzerland address & already updated that she was
appointed there in 2012. Please advise if you have any additional points to
add?
E — The "How Was the Client(s) Introduced? How long has the RM personally
known the client?" field talks about Zorro Management. Please amend. —
Updated as appropriate.
F — New fields were added as part of Dbforce change last weekend. Please
ensure those fields are filled out. — Please advise on the following
additional points for this case, as appropriate:
EFTA01415304
I look forward to your response at the earliest in resolving these
rejections, thanks.
Kind Regards,
{cid:1 =C7BBF707DF9B04F18f9e8a93df9386909@db.com}
Vijay Sawant
KYC Case Representative
Deutsche CIB Centre Private Limited
Deutsche Bank Group
Wealth Management
B1, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway
Goregaon East, Mumbai - 400063 , India
Tel.
Mobile
From: Vijay-A Sawant
Sent: Monday, July 23 2018 12:22 PM
To: Bradley Gillin
Cc: Stewart Oldfield <EMS
Subject: RE: Assistance Required in solving rejection points on KYC
Case/1111111i [I]
Importance: High
Good Morning Brad/Stewart,
A kind reminder of the below rejected case & an update as well.
Please note that as per latest update on CDD form delivery options (refer
attached email from AML), we are able to verify signatures of authorized
individual from signature card, corporate resolution, etc. I am able to
EFTA01415305
verify Mr Epstein's signature with 2017 Corp Resolution found in the
repositories in this case. This resolves one of the rejection points below
for us .7
So just summarizing the only pending item for this case now —
COGS for Prytanee, LLC. (We would require the client to send
latest COGS, dated within the last 6 months)
Let me know if you have any queries, thanks.
Kind Regards,
{cid:1 =C7BBF707DF9B04F18f9e8a93df9386909@db.com}
Vijay Sawant
KYC Case Representative
Deutsche CIB Centre Private Limited
Deutsche Bank Group
Wealth Management
B1, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway
Goregaon East. Mumbai - 400063 , India
Tel.
Mobile
From: Vijay-A Sawant
Sent: Tuesday, July 17, 2018 12:38 PM
To: Bradley Gillin
Cc: Stewart Oldfie
Subject: RE: Assistance
caseillIIIIIII[I]
Importance: High
Required in solving
>
rejection points on KYC
EFTA01415306
Hi Brad/Stewart,
As discussed yesterday, kindly procure COGS dtd within the last 6 months for
the acct holding entity.
I look forward to the Fincen form when available, thanks.
Kind Regards,
{cid:1 =C7BBF707DF9B04F18f9e8a93df9386909@db.com}
Vijay Sawant
KYC Case Representative
Deutsche CIB Centre Private Limited - Deutsche Bank Group
Wealth Management
Bl, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway
Goregaon East, Mumbai - 400063 , India
Tel.
Mobile
From: Bradley Gillin
Sent: Thursday, July 12, 2018 7:00 PM
To: Vijay-A Sawant
Cc: Stewart Oldfield
Subj
•
•
ssistance Required in solving rejection points on KYC
Case
[I]
Classification: For internal use only
Vijay,
I have searched far and wide, and on the US Virgin Island entity search
EFTA01415307
website. No sign of the COGS.
Do we really need this for an existing
account?
Regards,
Brad
{cid:image001.gif@01D419C1.30005250}
Bradley Gillin
Vice President
Deutsche Bank Wealth Management
345 Park Avenue, 24th Fl
New York NY 10154
Tel.
Fax
Email
Securities offered through Deutsche Bank Securities Inc.
From: Vijay-A Sawant
Sent: Thursday, July 12, 2018 8:43 AM
To: Bradley Gillin
Stewart Oldfield
Subj
•
•
ssistance Required in solving rejection points on KYC
Case
[I]
Importance: High
Hi Brad,
Many thanks for the below email. I have taken care of most of the rejection
points now.
Regarding the COGS query, I am looking for something like the attached.
Could you advise?
EFTA01415308
I look forward to Fincen update when available, thanks.
Regards,
(cid:1 =C7BBF707DF9B04F18f9e8a93df9386909@db.com}
Vijay Sawant
KYC Case Representative
Deutsche CIB Centre Private Limited
Deutsche Bank Group
Wealth Management
B1, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway
Gore aon East Mumbai - 400063 , India
Tel.
Mobile
From: Bradley Gillin
Sent: Wednesday, Jul 11, 2018 8:07 PM
To: Vi'a -A Sawant
Stewart Oldfield
Subj
•
•
ssistance Required in solving rejection points on KYC
Case
[I]
Importance: High
Classification: For internal use only
Vijay,
See below. Call if you have questions. Thanks again.
2) The address on the LLC Agreement does not match the address in the LLC
EFTA01415309
Agreement. Please provide proof of address.
This makes no sense - LLC agreement do not always accurately reflect address
as companies move.
Address is:
6100 RED HOOK QUARTER, B3
ST. THOMAS 00802
UNITED STATES VIRGIN ISLANDS
DB Statement is attached. CDD form in the case's attachments also reflects
this.
6) Can you please locate the full e-mail chain that proves that Chip
Packards approval actually refers to Epstein's jail sentence? The current e-
mail attachment uploaded does not refer to what is actually being discussed.
Exco approval, in attachments, from Patrick Campion, further
supports.
8) Please provide SOW verification for Jeffrey Epstein.
He is a Billionaire. Jeffery Epstein is a client at DB. Personal
account balance = $4mn.
Last KYC including Epstein approved case #
— 2/13/2018
9) Please complete SOW narrative for Caroline and provide SOW verification
as well.
The source of wealth for Caroline Lang derives from her employment
as Chairman of Sotheby's Switzerland. Caroline Lang is internationally
recognized for her in-depth knowledge of the art market and her longstanding
expertise in Impressionist, Modern and Contemporary art. Appointed Chairman
of the Swiss Department of Impressionist, Modern & Contemporary Art in 2012,
this consummate polyglot has advised some of the most important collectors
EFTA01415310
in Switzerland and worldwide. In November 2011, she played a decisive role
in the New York sale of Abstraction-Figuration, an exceptional private
collection of abstract works by Gerhard Richter and Max Ernst which realized
a world auction record for a work by Richter at the time. Caroline Lang has
also conducted major marathon auctions in Switzerland, the UK and Germany,
including the historic week-long sales of works of art from Monrepos Castle
in Ludwigsburg in 2000 and the Royal House of Hanover in 2005. Ms Lang also
serves as an executive for Warner Brothers Inc,.Her annual income is approx.
450k.
Sotheby's is one of the most prominent and well know art auction
houses in the world. If she is the chairman, that should be verification.
10) The SOW narrative for Jeffrey Epstein seems a bit outdated. It still
refers to the Financial Trust
Company as the SOW Company. However, based on the consent of board of
directors meeting from 2013, Financial Trust Company merged into Southern
Financial LLC with Southern Financial LLC as the surviving entity. Please
updated the SOW narrative and provide research etc for the new entity.
Refer to Last KYC Approved case #
— 2/13/2018
Jeffrey Edward Epstein (born January 20, 1953) is an American
financier and registered sex offender in the United States. He worked at
Bear Stearns early in his career and then formed his own firm, J. Epstein &
Co. In 2008, Epstein was convicted of soliciting an underage girl for
prostitution, for which he served 13 months in prison. He lives in the US
Virgin Islands. Epstein taught calculus and physics at the Dalton School in
Manhattan from 1973 to 1975. Among his students was a son of Alan C.
Greenberg, chairman of Bear Stearns.
In 1976, Epstein started work as an options trader at Bear Stearns
where he worked in the special products division, advising high-net-worth
clients on tax strategies. Proving successful in his financial career, in
1980 Epstein became a partner at Bear Stearns.
In 1982, Epstein founded his own financial management firm, J.
Epstein & Co., managing the assets of clients with more than $1 billion in
net worth. In 1987, Leslie Wexner, founder and chairman of Ohio-based The
Limited chain of women's clothing stores, became a well-known client. Wexner
acquired Abercrombie & Fitch the following year. In 1992 he converted a
private school on the Upper East Side into an enormous residence. Epstein
later bought that property, in the wealthiest part of Manhattan. In 1996,
Epstein changed the name of his firm to the Financial Trust Company and, for
tax advantages, based it on the island of St. Thomas in the U.S. Virgin
Islands.
EFTA01415311
In 2003, Epstein bid to acquire New York magazine. Other bidders
were advertising executive Donny Deutsch, investor Nelson Peltz, media mogul
and publisher Mortimer Zuckerman, who had the New York Daily News, and film
producer Harvey Weinstein. They were ultimately outbid by Bruce Wasserstein,
a longtime Wall Street investor, who paid $55 million.
In 2004, Epstein and Zuckerman committed up to $25 million to
finance Radar a celebrity and pop culture magazine founded by Maer Roshan.
Epstein and Zuckerman were equal partners in the venture. Roshan, as its
editor-in-chief, retained a small ownership stake.
Presently, Mr. Epstein founded Southern Trust Company Inc, a
private consulting company that invests the assets of their clients and gets
their revenue from the return of these investments. Southern Trust invests
in different portfolios catered to their clients and makes their revenue
based on the returns and the fees associated with managing their client's
assets.
11) Please explain in detail what this account is being used for. What are
the monthly expenses of the company?
Deposit account related to art purchase. It couldn't be clearer in the
current description:
Jeffrey and Caroline share the same affinity for art and decided
to become partners investing in artwork from up and coming artists together.
They both invest equally in the purchases of the artwork.
13) Please provide COGS for Prytanee, LLC.
Explain?
17) Please provide proof of delivery for the FinCEN form. Please ensure it
was e-mailed by the same person who signed the form (Jeffrey Epstein).
Will revert shortly
EFTA01415312
Regards,
Brad
{cid:image001.gif@OlD41903.076060A0}
Bradley Gillin
Vice President
Deutsche Bank Wealth Management
345 Park Avenue, 24th Fl
New York. NY 10154
Tel.
Fax
Emai
Securities offered through Deutsche Bank Securities Inc.
From: Vijay-A Sawant
Sent: Friday, July 06, 2018 2:12 AM
To: Stewart Oldfield
Cc: Bradley Gillin
Subject: RE: Assistance Required in
Casein
Hi Stewart,
solving rejection points on KYC
Sure, you & Brad can call me Monday or Tuesday next week. Monday, I am
available till 10am your time and till 11:30am on Tuesday.
Regards,
{cid:1 =C7BBF707DF9B04F18f9e8a93df9386909@db.com}
Vijay Sawant
EFTA01415313
KYC Case Representative
Deutsche CIB Centre Private Limited
Deutsche Bank Group
Wealth Management
B1, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway
Goregaon East, Mumbai - 400063 , India
Tel.
Mobile
From: Stewart Oldfield
Sent: Friday, July 06, 2018 12:14 AM
To: Vijay-A Sawant
Cc: Bradley Gillin
Subject: RE: Assistance Required in solving rejection points on KYC
Case
Let's set up a time to discuss when Brad is back next week. Some of these
requests seem unreasonable, and AML should already have a lot of this info,
particularly anything relating to Jeffrey Epstein personally (since we have
so many accounts for him).
As for Chip's email, it predates me. And the other people on the email are
no longer at DB. So I don't see how I can get hold of the full email. But
again, Jeffrey has been through a complete rep risk process here and has
been signed off on repeatedly by management as we've done any KYC
remediation or new account opening.
Anyway, let's regroup next week so we can go back to AML with a
comprehensive set of responses.
Thanks
From: Vijay-A Sawant
Sent: Wednesday, July 04, 2018 9:15 AM
To: Stewart Oldfield ‹
>
EFTA01415314
Cc: Bradley Gitlin
Subject: Assistance Required in solving rejection points on KYC Case
Importance: High
Hello Stewart,
Hope you are well!!
I have received the following list of rejection points on KYC Case
relating to customer — Prytanee, LLC.
I need your assistance in resolving below highlighted points.
For Point 2 — As per attached constitutional doc, they (AML) are requesting
to update address mentioned on Pg 11 (Royal Palms Professional Building
address). I had updated address as per Pg 28 which is the IRS letter. Please
confirm whether to keep this address or amend it as per Pg 11?
For Point 6 — Could you provide the email that the AML team is seeking? I
only have the attached email (2nd pdf attachment) from the repositories.
For Points 8 & 9 — Kindly provide SOW info for Jeffrey & Caroline.
For Point 10 — This will be covered on Pts 8 & 9
For Point 11 — My existing comments on the DB deposit account is "the
purpose of this account is to managing the monthly expenses of the company"
as per previous KYC. Kindly advise, please?
EFTA01415315
For Point 13 — I am unable to procure SoS for this entity from the US Virgin
Islands company registry website - Department of Licensing and Consumer
Affairs. Kindly provide this please?
For Point 17 — Please provide the requested email.
Rejection:1) Please add the account number for the deposit account.
2) The address on the LLC Agreement does not match the address in the LLC
Agreement. Please provide proof of address.
3) Please expand on the nature of business. What do they do with the
investment in art work? Re-sell it?
4) Richard Kahn has been tagged as a si natory. However, as per the DB
Resolution uploaded under KYC —
he is not listed as a signatory. If
Darren is indeed not a signatory, please remove him from this KYC.
5) The Pierre Trust was created under the laws of USVI. Please re-run
research with that country as well.
6) Can you please locate the full e-mail chain that proves that Chip
Packards approval actually refers to Epstein's jail sentence? The current e-
mail attachment uploaded does not refer to what is actually being discussed.
7) Please attach the RDC Alert for Richard Kahn.
8) Please provide SOW verification for Jeffrey Epstein.
9) Please complete SOW narrative for Caroline and provide SOW verification
as well.
10) The SOW narrative for Jeffrey Epstein seems a bit outdated. It still
refers to the Financial Trust Company as the SOW Company. However, based on
the consent of board of directors meeting from 2013, Financial Trust Company
merged into Southern Financial LLC with Southern Financial LLC as the
surviving entity. Please updated the SOW narrative and provide research etc
for the new entity.
11) Please explain in detail what this account is being used for. What are
the monthly expenses of the company?
12) Please complete the 90 and one year values. The one year value is listed
as $1MM, however, the account currently has just less than $200K.
EFTA01415316
13) Please provide COGS for Prytanee, LLC.
14) The account opened date in the KYC does not match the account opened
date in DbForce. Please re-concile.
15) Please add the state to Darren Indyke and Richard Kahn's address.
16) Please add the TAX ID/Identification number for Caroline.
17) Please provide proof of delivery for the FinCEN form. Please ensure it
was e-mailed by the same person who signed the form (Jeffrey Epstein).
18) Please provide google searches for the appropriate entities and
individuals. Please ensure you use the most up to date search string that is
located in the US country addendum to the KOPs.
I am working on rest of the points in the meanwhile. Thanks in advance.
Kind Regards,
{cid:1 =C7BBF707DF9B04F18f9e8a93df9386909@db.com}
Vijay Sawant
KYC Case Representative
Deutsche CIB Centre Private Limited - Deutsche Bank Group
Wealth Management
Bl, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway
Goregaon East, Mumbai - 400063 , India
Tel.
Mobile
EFTA01415317
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